POLICY OF RECORDING PERSONAL DATA VIA VIDEO SURVEILLANCE SYSTEM
The herein Policy describes the terms and conditions, under which a closed circuit television system (CCTV system) has been installed and is in function in Alimos Marina by the company "DEVELOPMENT OF NEW ALIMOS MARINA CONCESSION SINGLE MEMBER SOCIETE ANONYME"and with the distinctive title “DEVELOPMENT OF NEW ALIMOS MARINA SINGLE MEMBER S.A.”(based in Kifissia, Attica, 25 Ermou Street, VAT Number 801197209, Trade Registry number No. 151536301000), (hereinafter the "Company").
Α. FIELD OF APPLICATION – SCOPE
The installed video surveillance system (CCTV) records the motions of the incoming data subjects, in the area of Alimos Marina as analyzed below:
Β. DATA CONTROLLER
The Company is the Controller of your personal data, received through the video surveillance system, according to the General Regulation 2016/679 of the European Union (General Data Protection Regulation, hereinafter referred to as "GDPR"), Law 4624/2019, as in force, the relevant Guidelines of theHellenic Data Protection Authority(HDPA) (Guideline 1/2011 "Use of video surveillance systems for the protection of persons and property") and the relevant Guidelines of the European Data Protection Board (Guideline 3/2019 on processing of personal data through video devices).
C. LEGALBASIS FOR THE DATA PROCESS
The legal basis for the process of personal data, which is recorded via the video surveillance system, is articles 6.1.c and f of the General Data Protection Regulation (GDPR). The process is mandatory for the Controller’s compliance with his legal obligation, as per the proper preservation and protection of the vessels, docking in Alimos Marina (art. 3 of the General Regulation of Operation of Tourist Ports, Joint Ministerial Decision no. T/9803, no. 1323 B’/16-09-2003Government Gazette), as well as for the purposes of the legal interests pursued by the Company (protection of persons and property in case of illegal events).
D. PROCESSOF DATA – THE PROCESSOR
The process of the recorded personal data obtained via the video surveillance system, has been assigned by the Company, as the Controller, to the company “G4S Secure Solutions S.A.” (hereinafter referred to as "G4S"), based in Metamorfosi, Attica, at Sorou Street no. 7, P.C. 14452, withTrade Registry no. 002745601000, VAT no. 094500633 Tax Office: FAE Athens). The company G4S processes the recorded data as the Processor, under a contract signed between the Company and G4S, where the terms and obligations of the parties,regarding the process of personal data, as set out in Articles 24 and 28 of GDPR, are thoroughly reported.
Ε. DATA RECORDING THROUGH THE VIDEO SURVEILLANCE SYSTEM
For the surveillance of the facilities of Alimos Marina, digital (IP) fixed bullet cameras, as well as mobile cameras (PTZ) with rotating capability, which support software for embedding image analysis algorithms (Video Content Analytics) and which compose the video surveillance system of the Marina, have been installed and are in use since 01/01/2021.
F. DATA SECURITY MEASURES
The Company, in the context of the specific process of personal data, has taken the following applicable Data Security Measures:
The aforementioned security measures applied by the Company, are updated either on a regular basis or on an “ad hoc” (by case) basis, due to possible emergency circumstances, so that these data security measures,shall always be effective and provide the highest possible degree of protection to the information and personal data being processed, in accordance with the above reported.
G. TRANSMISSION OF PERSONAL DATA
The Company may transmit the personal data of the subjects, only to third party services providers, whoperform services on behalf of the Company, as per the scopes described in this Policy, to the extent that this is necessary for the implementation of the scope of the process. In this case, the Company will take all the necessary measures, so that the services providers, shallbe specifically authorized for this purpose and completelybound byconfidentiality, and the obligations pursuant to the legal framework, regarding the collection and process of personal data.
H. RIGHTS OF DATA SUBJECTS
The Company, in order to preserve these data in accordance with the provisions of the General Data Protection Regulation 2016/679 and Law 4624/2019, takes all mandatory technical and organizational measures, for the secure process of these data,in order to ensure the appropriate security level of data against risks e.g. destruction, loss, alteration, unreasonable disclosure / access, unauthorized read-copy, modification or erasure of personal data,as well as the confidentiality, integrity, security, availability and reliability of the process systems and services, on an uninterrupted basis.
The Company, does not process the above data for different scopes than the aforementioned, and only processes theabsolutely necessary personal data, for the scope of each process, which always takes place on a legitimate basisand in accordance with the spirit and terms of the General Regulation, Law 4624/2019 and the effective legislation.
More specifically and particularly, as per the right of access and erasure of personal data, the below mentioned procedure is followed:
Therespectivedatasubject,shall address awrittenrequesttotheDataProtectionOfficer (DPO) oftheCompany, bysendingane-mailto[email protected], requesting access to his recorded personal data, and if he wishes, he can request their erasure.
The Data Protection Officer shall respond to the respective query of the data subject within fifteen (15) days, when he will inform the subject about the progress of his request, as well as per its implementation. Upon the above query of the data subject regarding the erasure of his personal data, the Company erases the recorded personal data, unless, there is an obligation or provision that requires the preservation of the recorded personal data, by the effective legislation or the applicable regulatory framework.
For the exercise of the above rights, as well as for any other information or question regarding the process of their personal data, the data subjects may contact Mrs. Margarita Skarou ([email protected], tel. 2106635982) who has been appointedthe Data Protection Officer of the Company "DEVELOPMENT OF NEW ALIMOS MARINA SINGLE MEMBER S.A.".
In case any of the above rights, is exercised (apart from the right of access and erasure of data, as analyzed above) by the respective subject, the Company shall take all possible measures to satisfy this request, within thirty (30) days of its receipt, when there will be respective updateon its progress. It is expressed that the aforementioned deadline, can be extended for two (2) additional months, taking into account the complexity of the request, as well as the total number of requests in general. These rights are exercised at no costfor the data subject, unless they arefrequently repeated and due to theirexcessity, administrative costs are implied for the Company, in which case, the applicant will bear the relevant costs.
In any case, the data subject has the right to appeal to the Hellenic Data Protection Authority (HDPA–Kifisias Avenue no. 1-3, P.C. 115 23, Athens, Telephone: 210 6475600, E-mail: [email protected]r, https://www.dpa.gr/) whether he considers, that his rights regarding the process of his personal data are violated, and he has not been satisfied with the Company's response, as the Controller.
Ι. AMENDMENTS IN THE CURRENT POLICY
The Company reserves the right toamend this Policy at any time. The amendments in this Policy, will be published on the Website www.alimos-marina.gr, while the Policy is also available in printed form at the Headquarters of Alimos Marina (Administration Offices). The User must review the Policy for any amendments or additions, and the Company has no obligation to inform each User individuallyregarding his rights.
DATE OF LAST UPDATE: 01/01/2021
|Entrance coordinates : East: 23º 42' 03''
North: 37º 54' 68''